Meacham v. United States
2:22-cv-00149
E.D. Tenn.Mar 11, 2025Background
- Brandon David Meacham pleaded guilty to being a felon in possession of a firearm, in violation of 18 U.S.C. § 922(g)(1), following his 2018 arrest in Tennessee.
- The facts underlying his conviction included his admission to possessing a handgun found during a vehicle search, and his prior armed robbery conviction.
- Meacham was sentenced to 63 months’ imprisonment and did not appeal his sentence directly.
- More than two years after his conviction became final, Meacham filed a habeas petition under 28 U.S.C. § 2255, seeking to vacate his sentence.
- His argument relied on the Supreme Court’s 2022 decision in New York State Rifle & Pistol Ass'n v. Bruen, claiming it rendered § 922(g)(1) unconstitutional as applied to felons.
- The United States opposed, citing procedural default, untimeliness, and a lack of substantive merit to Meacham’s constitutional claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of 18 U.S.C. § 922(g)(1) post-Bruen | Bruen makes felon-in-possession statutes unconstitutional | Bruen did not address or invalidate § 922(g)(1); it remains valid and lawful | § 922(g)(1) remains constitutional |
| Procedural default due to lack of direct appeal | Procedural default should be excused due to actual innocence post-Bruen | Defaulted; petitioner not actually innocent and cannot excuse failure to appeal | Not excused; no actual innocence; claim defaulted |
| Timeliness under § 2255(f) statute of limitations | Bruen created a new, retroactively applicable right, extending limitations | Bruen did not create a new right or rule applicable retroactively | Not timely; limitations period based on conviction |
| Equitable tolling | N/A (No facts alleged supporting equitable tolling) | Petitioner not diligent and no extraordinary circumstances | Not applicable; no equitable tolling shown |
Key Cases Cited
- United States v. Frady, 456 U.S. 152 (heightened standard for collateral challenges under § 2255)
- Bousley v. United States, 523 U.S. 614 (actual innocence exception for procedurally defaulted claims)
- Reed v. Farley, 512 U.S. 339 (requirements for non-constitutional claims under § 2255)
- Sanchez-Castellano v. United States, 358 F.3d 424 (finality of conviction for purposes of § 2255 limitations)
- Holland v. Florida, 130 S. Ct. 2549 (equitable tolling standard for habeas petitions)